In last month’s 4 The Record, Roy Rakiewicz reminded us of the angst created for Environmental Managers by the major New Source Review (NSR) air permitting rules. Roy talked about how changes at existing major air sources could qualify as major modifications under the NSR rules that include both the Non-Attainment NSR (NNSR) and the Prevention of Significant Deterioration (PSD) regulations. He described important terms used in assessing the applicability of these rules and explained that some are defined in the regulations and some are not. Roy reminded us that modifications are defined in the major NSR rules as including both physical changes as well as changes in the method of operation of a source. He also talked about the regulated NSR pollutants, significant emission increase rates, netting, and other important aspects of determining whether the rules apply to upcoming facility changes.
While he included a lot of regulatory detail interspersed with agency guidance, court interpretations, and information gained from years of on-the-job experience, the key point of Roy’s article was to be sure the message is out there that any changes that occur at a major source need to consider the potential applicability of the major NSR rules. This even includes changes that would be expected to result in emission decreases, such as converting an existing solid/liquid fuel-fired boiler to natural gas firing. This month we want to review some processes and planning that, if put in place, can help Environmental Managers be prepared when the next new project approval request lands on their desk. It’s never easy to tell the “powers that be” that their project schedule needs to include an additional 12 months for air permitting, or that they’ll need to add 3.5 million dollars for additional air pollution controls that were never considered, but these situations occur more often than one would expect these days.
So what can an Environmental Manager do to help avoid the situation where they become that surprise bearer of bad news?